from John v CBS lawsuit, this goes to the question of which came first, the blow to the head or death by strangulation.

187. The medical examiner found the cause of JonBenét’s death was asphyxia by
strangulation with the garrote associated with craniocerebral trauma.
188. The medical examiner found physical evidence that conclusively established that
JonBenét was alive at the time she was asphyxiated.
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189. There were physical findings on her body that strongly suggested that JonBenét
struggled with her attacker and was conscious at the time she was garroted.
190. JonBenét’s neck had fingernail abrasions and scrapes in the area where the garrote
was embedded in her neck.